MAY 2017 IP: 17-03-A

ISSUE PAPER CRYING FOWL: MAJOR GROCERS STUMBLE IN PROMOTING ANTIBIOTIC STEWARDSHIP IN RETAIL CHICKEN

SUMMARY Across the country, scientists, physicians, and public health advocates have been sounding the alarm over rising rates of antibiotic resistance, one of the major public health crises of our time. According to the Centers for Disease Control and Prevention, each year at least 23,000 people in the United States lose their lives to antibiotic-resistant infections and an additional two million are sickened. Prominent health organizations such as the World Health Organization (WHO), the Infectious Disease Society of America, and the American Academy of Pediatrics agree that overuse of antibiotics in poultry and livestock production, in addition to human medicine, is a major contributor to antibiotic resistance.

While the federal government, including the U.S. Food available to consumers concerned about routine antibiotic and Drug Administration (FDA), has been slow to curb the use: routine use of antibiotics, consumers have been driving n U.S. Department of Agriculture (USDA) Certified Organic; change by voting with their wallets. Consumers visit supermarkets 1.5 times per week, exerting enormous n chicken labeled “raised without antibiotics”(RWA), a purchasing power over what these stores carry. So, when which is sometimes USDA process verified; and consumers buy more meat and poultry raised without the n unlabeled chicken from producers that have committed routine use of antibiotics, and demand these better meat to or have already transitioned away from routine use, choices, they exert powerful influence on the marketplace. while allowing use when animals are sick. And it is in the chicken industry that we have seen the NRDC considers all three options representative of fastest response to consumer demand. responsible antibiotic practices or a commitment to A significant number of chicken producers and fast-food implement such practices. chains have made public commitments in the past two Grocery retailers are the middlemen who bring meat years, pledging to phase out the routine use of antibiotics products to consumers. Their product selections grant that are important for human medicine (“medically consumer access to meats raised without routine antibiotic important antibiotics”) in raising chickens. Thanks to these use. Retailers can either spur improved antibiotic commitments, several types of chicken products are now stewardship by producers or reward continued routine use. a “Raised without antibiotics” (RWA) is used as a broad term that includes other labels, such as “No antibiotics ever” and No antibiotics added,” indicating that antibiotics were not administered to chickens. b Both USDA Certified Organic and USDA process-verified RWA chicken brands reflect antibiotic use claims that have been verified by an independent third party.

The authors are grateful for the helpful comments of Laura Rogers (Antibiotic Resistance Action Center), Steve Roach (Food Animal Concerns Trust), Kathy Lawrence (School Food Focus) and Vanessa Zajfen (School Food Focus) as well as from Miriam Rotkin-Ellman (NRDC) and Valerie Baron (NRDC).

For more information, please contact: www.nrdc.org Jonathan Kaplan, [email protected] www.facebook.com/nrdc.org Carmen Cordova, [email protected] www.twitter.com/NRDC We evaluated the five largest grocery retailers in North n While most grocery stores surveyed offered RWA America on their offerings of chicken brands from producers or USDA Certified Organic chicken, they often with responsible antibiotic practices and their public lacked signage to direct consumers to these commitments around antibiotic use. We also examined their offerings. The absence of signage makes it less likely signage and informational materials directing consumers’ that consumers will find the products or even notice attention to chicken raised without the routine use of that they are there. Publix stood out for its signage at antibiotics, as well as the extent to which suppliers’ claims every surveyed location. regarding antibiotic use were verified by an independent n The proportion of brand choices with verified third party.b Specifically, the retailers we surveyed were claims about antibiotic use varied widely from Costco, Publix, Walmart, Albertsons/Safeway, and Kroger. grocer to grocer (20 to 50 percent). Third-party Overall, unfortunately, we found that all five retailers certification of responsible antibiotic use claims provides have failed to provide leadership in promoting responsible independent assurance of claimed practices and builds antibiotic practices in their supply chains. consumer confidence. Generally, grocers with the most brand choices had a smaller fraction of brand choices with verified responsible antibiotic use claims. For KEY FINDINGS example, Publix offered a total of 17 different brand n All five grocery retailers offered at least one brand choices in the two cities we surveyed, but only three choice reflective of responsible antibiotic use brand choices had third-party-verified antibiotic use practices, and most offered several such choices. claims. At the same time, Costco generally offered two In many cases, these offerings reflected the majority of brand choices at every store location, including one the brand choices for the locations and period covered by option whose antibiotic use claims were verified. the survey. For instance, 90 percent of the brand choices at the Walmart stores we surveyed were from producers RECOMMENDATIONS that report using fewer antibiotics. While this is a step in the right direction, retailers are still falling short in To promote more responsible use of antibiotics in their significant ways. chicken supply chains, retailers should: n None of the major retailers had publicly committed n Develop responsible antibiotic use policies and to eliminating routine antibiotic use in their chicken communicate those policies to consumers. While some retailers have policies, supply chains. n Improve signage to draw consumers’ attention to chicken they are not strong enough. None of the five retailers products that make claims about responsible antibiotic we surveyed had an antibiotics policy for their chicken use, i.e., USDA Certified Organic or RWA products. (or other meat) that includes a time-bound commitment to phase out routine use of antibiotics in their chicken n Encourage producers to work with the USDA to develop supply chains. While responsibly raised chicken brands new designations that reflect responsible practices but were available on their shelves, the lack of corporate are not USDA Certified Organic or USDA process-verified policies means that many retailers may be selling larger RWA. volumes of chicken raised with routine antibiotic use. The n Work with producers to push for third-party certification lack of an explicit commitment also means retailers may or verification of responsible antibiotic use claims. not be providing brand choices that reflect responsible antibiotic practices at all locations, and they may not be stocking them all the time.

Page 2 CRYING FOWL: MAJOR GROCERS STUMBLE IN PROMOTING ANTIBIOTIC STEWARDSHIP IN RETAIL CHICKEN NRDC DRAFT Not all chickens are raised equally

Of all the antibiotics sold in the United States that are Reducing antibiotic use is critical to stemming the tide of important for human medicine, approximately 70 percent resistance. Consumers are increasingly asking for meat are sold for poultry and livestock use.¹ These antibiotics raised without the routine use of antibiotics, from both fast- are similar to or the same as the antibiotics that patients food chains and grocery retailers.8 U.S. consumers trek to receive from their doctors, and their overuse in animal the supermarket 1.5 times per week, on average.⁹ When they agriculture as well as in human medicine has led to hard- start demanding and buying more meat and poultry raised to-treat, antibiotic-resistant infections that threaten without the routine use of antibiotics, consumers exert a human health. Many of these drugs are approved to help powerful influence on the marketplace. Major producers animals survive the stressful, overcrowded, or unsanitary from the chicken industry have led the transition away from living conditions found in industrial livestock operations.² the routine use of antibiotics, probably because chickens When antibiotics are given to chickens, pigs, and cattle have shorter life cycles than other meat animals (and likely routinely, the drugs kill off susceptible bacteria, leaving the fewer chances to contract infections).10,11,12 Large chicken resistant bacteria to survive, multiply, and spread.³ These producers such as Perdue, Tyson, and Foster Farms have antibiotic-resistant bacteria can then travel into the general all committed to phasing out the routine use of medically population via poultry and livestock products, farmworkers, important antibiotics (see Table A4). Similarly, a growing or contaminated air, water, and soil.⁴ Antibiotic-resistant number of major fast-food restaurant chains have pledged bacteria can also pass on their resistance to other species of to purchase chicken raised without the use of medically bacteria that can infect people and make us sick, resulting important antibiotics, including McDonalds, Subway, in longer illnesses and more expensive treatments.⁵ Also, Wendy’s, and Chick-fil-A.13 These commitments demonstrate as antibiotics begin to fail, patients undergoing procedures that chickens can be raised and sourced on a large scale like surgeries and chemotherapy will be increasingly at risk without the routine use of antibiotics. of contracting untreatable infections. According to Thomas Frieden, director of the Centers for Disease Control and Prevention (CDC), “[A]ntibiotic resistance may be the single most important infectious disease threat of our time.”⁶ The CDC has stated that “much of antibiotic use in animals is unnecessary and inappropriate and makes everyone less safe.”⁷

Page 3 CRYING FOWL: MAJOR GROCERS STUMBLE IN PROMOTING ANTIBIOTIC STEWARDSHIP IN RETAIL CHICKEN NRDC DRAFT OUR SURVEY stores owned by each of these companies; in some cases, as shown in Figure 1, the regional store had a name that In the spring of 2016, NRDC surveyed retail chicken differed from that of its major grocery retailer. We surveyed products offered by the five largest North American grocery up to three locations per retailer in each city. retailers: Walmart, Kroger, Costco, Albertsons/Safeway, We photographed all unique chicken brand choices available and Publix.14 Combined, these retailers represent more than in the store as well as any signage directing consumers 50 percent of the market in North America.15 This survey to chicken raised without the routine use of antibiotics, provides a snapshot of the chicken brand choices found on including USDA Certified Organic and RWA options.17 To their grocery store shelves. Our survey covered Charlotte, identify the producer, we relied on brand information or Chicago, Houston, Jacksonville, Los Angeles, the processing plant number associated with the package.18 and Philadelphia, each of which has a population of at In many cases, private-label packaging or alternative brand least 700,000.16 labels masked the actual producer, which we identified To ensure broad representation in the survey sample, through the associated processing plant information. In a we set the following criteria for our choice of cities: small number of cases, we could not identify the chicken 1. At least three of the five retailers had to be located within producer due to missing processing plant information the metropolitan area (defined as 15 miles from the city on the package, and we did not include those products in center) and had to have multiple stores (for each retailer). our scoring. We conducted supplemental web research to identify grocery retailers’ antibiotic use policies and 2. Each of the four census regions of the United States had related statements. We received few responses to letters to be represented by at least one city. sent to retailers and producers reflected in the survey, 3. Each retailer had to be present in at least two of the six and those that we did receive did not provide relevant new cities surveyed. information. Table 1 describes the point system we used to grade each retailer’s antibiotic stewardship performance. The retailers we visited in each city are shown in Figure 1. Scoring results are listed in Table 2. Additional details, We aimed to maximize the population served by the five including regional retailer scores, are provided in retailers in the areas surveyed, resulting in more survey Appendices 1 and 2. activity in the South census region. NRDC visited regional

FIGURE 1: MAP AND TABLE OF RETAILERS VISITED IN EACH OF THE SIX MAJOR METROPOLITAN AREAS

Page 4 CRYING FOWL: MAJOR GROCERS STUMBLE IN PROMOTING ANTIBIOTIC STEWARDSHIP IN RETAIL CHICKEN NRDC DRAFT Major retailers are providing little leadership to promote the company is working to eliminate medically important antibiotic stewardship antibiotics from its chicken supply chains, but those As is evident from Table 2, none of the five retailers have statements have not translated to a time-bound commitment made a strong public commitment to eliminate the routine to do so on the company’s website.20 use of antibiotics from their chicken supply chains. None This overall finding stands in stark contrast to several large have published a policy that adopts specific goals to phase chicken producers, including Tyson, Perdue, and Foster out the use of antibiotics, either for their own private Farms, that over the past two years have transitioned labels of chicken or for other brands they carry. A Costco or have pledged to transition away from routine use of representative, for example, has stated to the media that

TABLE 1: SCORING INDICATORS Category Criteria How points were awarded Maximum Points

*Commitment to phase out routine use of 10 points for a commitment (5 point antibiotics described on major retailer website given for strong statements that suggest Policy 20 points AND a retailer is moving in this direction,

*Timeline to phase out routine use of antibiotics but do not constitute an official policy), described on major retailer website 10 additional points for a timeline *Retailer (in all cities where present) had at least one store with signage or informational materials that highlighted USDA certified organic, RWA, or no routine antibiotic use chicken options for Consumer consumers OR 5 point for consumer education in education at all cities, 2.5 points for consumer 5 points point of purchase *Retailer had, in a majority of cities where present, education in a majority of cities at least one store with signage or informational materials that directed consumer towards USDA certified organic, RWA, or no routine antibiotic use chicken options *Brand of chicken is USDA certified organic, RWA, Brand score or produced by a producer with Received points based on % brands that 20 points antibiotic use a commitment to phase out met criteria routine use of antibiotics Brand score *Label or website of producer indicates 3rd party Received points based on % brands that 10 points certification certification of antibiotic use claims met criteria 55 Points

TABLE 2: RESULTS OF SURVEY AND RESEARCH FOR FIVE MAJOR RETAILERS19 Consumer Brand score Brand score Raw score Policy score education score (antibiotic use) (certification) (55 points Major retailer (20 points) (5 points) (20 points) (10 points) maximum) Percent Grade

0 0 18 2.9 20.9 38% D

0 2.5 15.8 3.2 21.5 39% D

0 5 14.2 1.8 21 38% D

0 2.5 13.4 2.5 18.4 33% D

5 0 12.4 4.6 22 40% D

Page 5 CRYING FOWL: MAJOR GROCERS STUMBLE IN PROMOTING ANTIBIOTIC STEWARDSHIP IN RETAIL CHICKEN NRDC DRAFT antibiotics. Fast-food companies have been following TABLE 3: CHICKEN SUPPLIERS BEHIND PRIVATE LABEL BRANDS IN suit, as evidenced by public commitments and the annual RETAILER SURVEY “Chain Reaction” scorecard on antibiotic use policies and practices of major fast-food chains, published by a coalition USDA certified of environmental, public health, and consumer advocacy organic, raised without groups.21 antibiotics, Chicken chicken from Consumers receive little direction toward brand choices supplier producer that that reflect responsible antibiotic use practices from is phasing out Most grocery stores surveyed had very little signage retailer routine use, or informing consumers about the brand choices from Retailer Private labels survey conventional producers with strong public commitments to responsible Pilgrim’s Conventional use of antibiotics, even though many stores offered RWA Pride and USDA Certified Organic chicken brands. Only Publix Raised without had signage in all of the surveyed stores (see Table A3). Perdue As for brand choices from producers that are at least antibiotics committed to phasing out the routine use of antibiotics Raised without important to human medicine (but not RWA or USDA Tyson antibiotics Certified Organic), there is no way for consumers to identify these products. This is likely because producers have USDA certified Perdue not developed USDA-approved claims for these chicken organic products and because retailers have not developed their Sanderson own internal sourcing policies regarding routine antibiotic Conventional use. If chicken products do not communicate how they Farms are different from conventional products, consumers are Randall unlikely to find or choose them.22 Conventional Foods

Walmart stores had a strong selection of chicken brand choices Foster No routine use from producers with antibiotic stewardship commitments Farms Walmart had the largest proportion of chicken brand Sanderson choices sourced from producers with responsible antibiotic Conventional use commitments, with brand sourcing primarily from Farms Perdue and Tyson for its “conventional” chicken offerings Tip Top Conventional (see Table A2 below), despite the fact that Walmart allows Poultry 23 for routine use of these drugs in its antibiotics policy. Both Perdue and Tyson have committed to phasing out routine Pilgrim’s Conventional antibiotic use in their chicken production, although neither Pride had third-party certification for these claims on surveyed 24,25 Pilgrim’s Raised without conventional chicken packages. While the grocery retailer does not have a strong antibiotics policy, Walmart Pride antibiotics has called for greater transparency, including annual public Sanderson reporting of antibiotic use by its suppliers, which might Conventional Farms influence the industry in a positive direction.26 Interestingly, both Perdue and Tyson have been providing regular updates Foster No routine use to the public around their antibiotic use, although it is Farms unclear if these disclosures are related to Walmart’s public statements on this topic.27 Pilgrim’s Conventional Pride

UNMASKING RETAILER PRIVATE LABELS Foster USDA certified

Farms organic Retailers have great influence over the chicken production practices for their own store brand. Our investigation found little evidence that Foster Raised without

grocery chains are using this influence to offer chicken produced Farms antibiotics with fewer antibiotics. Instead, we found that retailers’ private- Mountaire label brands are generally not sourced from producers with strong Conventional antibiotic policies (see Table 3). This represents a lost opportunity Farms for retailers to promote more responsible antibiotic use.28 None None None

Page 6 CRYING FOWL: MAJOR GROCERS STUMBLE IN PROMOTING ANTIBIOTIC STEWARDSHIP IN RETAIL CHICKEN NRDC DRAFT Retailers offer USDA Certified Organic or RWA chicken CERTIFIED RESPONSIBLE ANTIBIOTIC USE: A LABELING on grocery shelves, but third-party verification is needed OPPORTUNITY FOR RETAIL CHICKEN? to ensure transparency and accountability and to build consumer trust Our survey found that only RWA and USDA Certified Organic retail All surveyed locations offered a USDA Certified Organic or chicken was labeled to highlight antibiotic use claims. However, RWA option (except Chicago Food 4 Less stores, part of the school meat buyers have a third option: certified responsible Kroger group). We found that in some stores, a majority of antibiotic use (CRAU).33 School Food Focus, which works with the chicken brand choices on the shelf were from producers school districts across the country, authored the CRAU standard with antibiotic stewardship commitments, indicating that to facilitate school district purchases of chicken from progressive consumers at those stores are selecting from producers producers that use medically important antibiotics only to treat with strong antibiotic use commitments; however, third- or control disease associated with a bacterial infection. This party certification of antibiotic use claims was, more often practice is equivalent to no routine use of antibiotics. The CRAU than not, absent (see Table A2 below). RWA and similar certification provides these producers with an opportunity for claims do not require third-party verification. As a result, recognition for responsible antibiotic use. It also allows schools to consumers are often left on their own to judge the veracity identify producers that are audited annually by the USDA to verify of antibiotic use claims. Some producers, like Perdue, conformance with the CRAU standard, which is publicly available. however, have voluntarily adopted a third-party verification Tyson and Perdue sell CRAU certified poultry products to school from the USDA for their RWA chicken production, which districts across the country. helps build consumer trust (see Table A2). Also, in our survey, no retailer offering chicken brand choices from We observed that—unless chicken was USDA Certified Organic a producer that had committed to phase out routine use or RWA—neither retailers nor producers communicated to the of antibiotics made these products easily identifiable. consumer their commitments to responsible antibiotic use. CRAU Consumers are increasingly aware of and want to support was created to allow buyers from schools to source chicken raised responsible antibiotic use, and third-party verification has with greater antibiotic stewardship and provide an essential level strong potential to build consumer confidence.29,30 of transparency and accountability in the school food market. If introduced in the retail space, CRAU-labeled chicken could inform concerned shoppers about producers that have phased out routine use of antibiotics. WHOLE FOODS EXHIBITS LEADERSHIP IN ALL CATEGORIES Although not included in this survey, Whole Foods would have earned top scores in all categories. Whole Foods sells only chicken CONCLUSION raised without antibiotics.31 This policy applies to all chicken, In the absence of federal action to curb antibiotic use in beef, swine, and turkey products, making an in-store survey livestock production, consumers have been driving the move unnecessary. Whole Foods consumers can easily understand away from routine use. As a result, chicken that is raised the antibiotic use practices associated with their purchase. without routine use of antibiotics has become more readily Whole Foods’ antibiotics claims are certified by the Global Animal available.34 While fast-food chains have integrated their Partnership (GAP).32 In contrast, the five major retailers evaluated antibiotic use commitments into their marketing and public in our survey rely largely on their consumers to determine and messaging, retailers have remained silent. Our survey found evaluate the antibiotic use practices for the chicken sold in their that retailers do not always give consumers the necessary stores, except when chicken is labeled USDA Certified Organic or information to make informed choices. Chicken from RWA. Our survey found that while some stores’ chicken offerings producers that are reportedly eliminating routine antibiotic were almost entirely sourced from producers exhibiting responsible use don’t indicate this commitment on the product label and antibiotic use practices, their consumers were often unaware there is no additional signage near the shelf. Also, since of this fact. With its policy and certified retail chicken, Whole many brand choices are not third-party verified, consumers Foods not only supports progressive producers but empowers typically have to trust the producer’s claim. However, some its consumers to choose wisely and to support these producers producers have begun incorporating third-party verification, as well. and we encourage retailers to highlight those producers and others that follow suit. Notably, producers such as Tyson, Perdue, and Foster Farms are reducing routine use of antibiotics in their more affordable, conventional chicken products. Retailers should take note and source conventional chicken under a responsible antibiotic stewardship policy.

Page 7 CRYING FOWL: MAJOR GROCERS STUMBLE IN PROMOTING ANTIBIOTIC STEWARDSHIP IN RETAIL CHICKEN NRDC DRAFT In the face of the growing threat of antibiotic resistance, Poultry producers should adopt clear, unambiguous NRDC calls on retailers to make strong commitments to commitments to phase out the routine use of medically eliminate the routine use of antibiotics from their supply important antibiotics. The FDA needs to take strong action chains. While Walmart is doing better than others in our to ensure that all livestock and poultry producers are survey in terms of providing better brand choices, all reserving these precious antibiotics to treat sick animals retailers should make every effort to provide chicken raised or to control disease outbreaks, instead of using them without routine use of antibiotics, with verifiable claims, preemptively to promote faster growth or compensate especially under their private labels and in all of their for overcrowded or dirty living conditions. stores. Retailers should also provide transparency and Consumers should continue to vote with their wallets accountability by requiring their suppliers to secure third- and purchase USDA Certified Organic and RWA chicken. party verification. Consumers can also reward producers committed to phasing out routine use of antibiotics across their entire production operations.

APPENDIX 1: METHODOLOGY

City/Retailer Selection and Methodology NRDC conducted an in-store, first-person research survey of five selected grocery companies in six cities spanning all four U.S. census regions. In order of population (based on 2014 U.S. Census data), those cities were Los Angeles; Chicago; Houston; Philadelphia; Jacksonville, Florida; and Charlotte, North Carolina.35 NRDC collected data on the five largest grocery retailers in the United States. These five retailers, representing 50.18 percent of the total retail grocery market in the nation, were Walmart (Los Angeles, Chicago, Houston, Philadelphia, Jacksonville, Charlotte), Kroger (Los Angeles, Chicago, Houston, Charlotte), Costco (Los Angeles, Chicago, Houston, Philadelphia, Jacksonville, Charlotte), Albertsons/Safeway (Los Angeles, Chicago, Houston, Philadelphia), and Publix (Jacksonville, Charlotte). The above cities and retailer selections met the following two criteria: (1) Presence of large U.S. retailers–all major retailers had to be present in at least two of the six cities selected; and (2) Balanced representation–cities selected were the most populous metropolitan areas in the nation that also had at least three of the top five large retailers, with multiple stores present within 15 miles of the city center.36

DATA COLLECTION

NRDC staff traveled to each of the six selected cities for image collection at retailer locations. For each city, NRDC staff selected up to a maximum of three random locations that were within a 15-mile radius of the city center. To ensure the randomness of store locations, all stores surveyed were randomly selected using a website that randomizes the order of items on a list (Random.org). NRDC staff then entered the selected stores and took representative photographs of all unique brand choices sold in the store. A unique brand choice was defined as every different combination of brand and antibiotic use claim among available fresh chicken products. NRDC staff documented their store visits as follows: First, an image was taken prior to store entry to document the store location. A photograph of the store’s meat section was then taken from a wide-angle distance, to gain an initial understanding of in-store signage pertaining to claims of “natural,” “organic,” etc. Photographs were taken such that each unique brand, processing plant number, or combination was documented. Processing plant numbers for poultry could be identified with the prefix P or E. Any education materials available, including in-store signage, were collected from the stores or photographed (see Figures A2 and A3, below). Visits took place between March 16 and March 31, 2016. Table A1 includes an overview of store locations and dates for the site visits. NRDC sent letters requesting additional information to all surveyed retailers on April 21, 2016, and all surveyed producers on June 9, 2016, well in advance of publication of this report. Figure A1 shows a representative letter that was sent to retailers and producers. Individual letters included minor variations.

Page 8 CRYING FOWL: MAJOR GROCERS STUMBLE IN PROMOTING ANTIBIOTIC STEWARDSHIP IN RETAIL CHICKEN NRDC DRAFT TABLE A1: OVERVIEW OF DATA COLLECTION

Major retailer/(Regional name, if different) Store location Date visited in 2016 Albertsons + Safeway/(Vons) 1430 S. Fairfax Ave., Los Angeles, CA March 16 Albertsons + Safeway/(Vons) 980 National Blvd., Los Angeles, CA March 16 Albertsons + Safeway/(Vons) 7311 N. Figueroa St., Los Angeles, CA March 16 Costco 2901 Los Feliz Blvd., Los Angeles, CA March 16 Costco 1345 N. Montebello Blvd., Montebello, CA March 17 Costco 2207 W. Commonwealth Ave., Alhambra, CA March 16 Kroger/(Ralphs) 4760 W. Pico Blvd., Los Angeles, CA March 16 Kroger/(Ralphs) 5429 Hollywood Blvd., Los Angeles, CA March 16 Kroger/(Food 4 Less) 5420 W Sunset Blvd., Los Angeles, CA March 16 Walmart 8500 Washington Blvd., Los Angeles, CA March 16 Walmart 1827 Walnut Grove, Los Angeles, CA March 16 Albertsons + Safeway/(Jewel Osco) 1340 North Canal St., Chicago, IL March 18 Albertsons + Safeway/(Jewel Osco) 2550 North Clybourn Ave., Chicago, IL March 18 Albertsons + Safeway/(Jewel Osco) 1220 South Ashland Ave., Chicago, IL March 17 Costco 1430 South Ashland Ave., Chicago, IL March 17 Costco 2500 Harlem Ave., Chicago, IL March 17 Costco 2746 North Clybourn Ave., Chicago, IL March 18 Kroger/(Food 4 Less) 4620 S. Damen Ave., Chicago, IL March 18 Kroger/(Food 4 Less) 7030 S. Ashland Ave., Chicago, IL March 18 Kroger/(Food 4 Less) 112 W 87th St., Chicago, IL March 18 Walmart 8331 S. Stewart Ave., Chicago, IL March 18 Walmart 4720 S. Cottage Grove Ave., Chicago, IL March 18 Walmart 570 W. Monroe St., Chicago, IL March 18 Costco 2125 Mathews Township Parkway, Charlotte, NC March 24 Costco 500 Tyvola Rd., Charlotte, NC March 24 Kroger/(Harris Teeter) 8535 Park Rd., Charlotte, NC March 24 Kroger/(Harris Teeter) 5030 Park Rd., Charlotte, NC March 24 Kroger/(Harris Teeter) 1621 Sardis Crossing Dr., Charlotte, NC March 24 Publix 8120 South Tryon, Charlotte, NC March 24 Publix 12810 South Tryon, Charlotte, NC March 24 Publix 2222 South Blvd., Charlotte, NC March 23 Walmart 1830 Galleria Blvd., Charlotte, NC March 24 Walmart 3850 East Independence Blvd., Charlotte, NC March 24 Walmart 9820 Callabridge Ct., Charlotte, NC March 23 Albertsons + Safeway/(Randalls) 2075 Westheimer Rd., Houston, TX March 31 Albertsons + Safeway/(Randalls) 5586 Weslayan St., Houston, TX March 31

Page 9 CRYING FOWL: MAJOR GROCERS STUMBLE IN PROMOTING ANTIBIOTIC STEWARDSHIP IN RETAIL CHICKEN NRDC DRAFT TABLE A1: OVERVIEW OF DATA COLLECTION Albertsons + Safeway/(Randalls) 2225 Louisiana St., Houston, TX March 31 Costco 3836 Richmond Ave., Houston, TX March 31 Costco 1150 Bunker Hill Rd., Houston, TX March 31 Kroger 1801 S. Voss Rd., Houston, TX March 31 Kroger 1035 N. Shepherd Dr., Houston, TX March 31 Kroger 6322 Telephone Rd., Houston, TX March 31 Walmart 9700 Hillcroft St., Houston, TX March 31 Walmart 2727 Dunvale Rd., Houston, TX March 31 Walmart 10411 N Freeway 45, Houston, TX March 31 Costco 4901 Gateway Pkwy., Jacksonville, FL March 21 Publix 2033 Riverside Ave., Jacksonville, FL March 22 Publix 4495 Roosevelt Blvd., Jacksonville, FL March 22 Publix 7749 Normandy Blvd., Jacksonville, FL March 22 Walmart 8011 Merrill Rd., Jacksonville, FL March 22 Walmart 6855 Wilson Blvd., Jacksonville, FL March 22 Walmart 8808 Beach Blvd., Jacksonville, FL March 22 Albertsons + Safeway/(Acme) 309 S. 5th St., Philadelphia, PA March 30 Albertsons + Safeway/(Acme) 6640 Oxford Ave., Philadelphia, PA March 30 Albertsons + Safeway/(Acme) 8500 Henry Ave., Philadelphia, PA March 29 Costco 100 Veterans Way, Warminster, PA March 29 Costco 201 Allendale Rd., King of Prussia, PA March 29 Walmart 2200 Wheatsheaf Ln., Philadelphia, PA March 30 Walmart 1675 S. Christopher Columbus Blvd., Philadelphia, PA March 30

SCORING

According to current estimates, only about 40 percent of the chicken offered for retail sale nationwide is from a producer that is committed to phasing out routine use of antibiotics (or is USDA Certified Organic or RWA), and many producers are still in transition.37 It is critical that retailers offer many brand choices from suppliers that produce chicken raised with responsible antibiotic use, regardless of whether there is certification for some products or consumer education to direct consumers to better brand choices. Accordingly, we weighed the initial steps of good retailer antibiotics policies and good chicken brand sourcing more heavily (20 points each) in our scoring rubric than consumer education (5 points) and third-party verification of producer antibiotics claims (10 points). As more and more producers meet their goals to phase out routine use of antibiotics and more good brand choices appear on the grocery store shelf, certification and consumer education will take on increased importance. See Table 2 of the main text for the scoring indicators. Based on percentage scores, we assigned grades to the retailers as follows: A, 81–100; B, 61–80; C, 41–60; D, 21–40; and F, 0–20.

Page 10 CRYING FOWL: MAJOR GROCERS STUMBLE IN PROMOTING ANTIBIOTIC STEWARDSHIP IN RETAIL CHICKEN NRDC DRAFT FIGURE A1: SAMPLE LETTER SENT OUT TO RETAILERS AND PRODUCERS IN THE SURVEY

[Date]

CONTACT NAME AND ADDRESS

Dear [CEO],

On behalf of [list organizations], NRDC is writing to ask for your leadership to encourage antibiotic stewardship in the livestock industry, and to ask for an update of your company’s current policies regarding antibiotic use in the production of meat and poultry sold in your stores. We are currently engaged in a nationwide study and “scorecard” focused on the antibiotic use policies guiding sourcing practices of major U.S. grocery retailers, as they relate to medically important antibiotics. NRDC and allied groups recently published a report and scorecard focused on the antibiotic use policies of major fast-food restaurants in the U.S. (see “Chain Reaction: How Top Restaurants Rate on Reducing Use of Antibiotics in Their Meat Supply,” attached). The findings were covered by news outlets across the nation, reflecting a large amount of consumer interest around the issue of antibiotic use in food production. In an effort to provide consumers information about antibiotic use in the production of retail meat, this project focuses on the antibiotic stewardship practices of the five largest grocery retailers in the country, including [COMPANY NAME]. According to the Centers for Disease Control and Prevention, the rise of bacteria resistant to commonly relied-upon antibiotics is one of our most pressing public health threats. Each year in the U.S., two million people contract antibiotic-resistant infections and 23,000 die as a result. Due to worsening resistance, future organ transplants, cancer chemotherapy, dialysis, and other medical procedures that rely on effective antibiotics are at risk. While overuse of antibiotics in human medicine is a major contributing factor, the nation’s health experts agree that feeding low doses of antibiotics to animals that are not sick also contributes to the rise of antibiotic-resistant bacteria. Increasingly consumers are asking for meat raised without the routine use of these drugs. Some major food companies are demonstrating leadership to curb this threat. As you are likely aware, Costco announced early last year that it would eliminate routine use of medically important antibiotics in its entire U.S. chicken supply. Last year, McDonald’s committed to sourcing chicken raised without medically important antibiotics within two years across their 14,000 U.S. restaurants. Subway, Chick-fil-A, Papa John’s, and many others have also committed to strong antibiotics stewardship practices for the chicken they serve. This study will focus on the antibiotic stewardship policies published by major retailers and their suppliers of fresh meat. We may also review statements, social media communications, and other publicly available antibiotics stewardship commitments [COMPANY NAME] has made. Following the spirit of the Chain Reaction report, we will evaluate the degree to which retailers and meat producers are: 1. Acting now to end the use of medically important antibiotics in the production of chicken (a sector where stewardship is now widely demonstrated), except as necessary to treat birds diagnosed with an illness;

Page 11 CRYING FOWL: MAJOR GROCERS STUMBLE IN PROMOTING ANTIBIOTIC STEWARDSHIP IN RETAIL CHICKEN NRDC DRAFT FIGURE A1: SAMPLE LETTER SENT OUT TO RETAILERS AND PRODUCERS IN THE SURVEY

2. Defining a time-bound action plan to phase out the routine use of antibiotics (i.e., for growth promotion and disease prevention) across all fresh meat supply chains, including chicken, turkey, beef, and pork (antibiotics should be available to treat animals diagnosed with an illness); 3. Adopting third-party audit program and benchmarking results that show progress in meeting the goals described above. To ensure that we correctly characterize your company’s efforts, we hope that by April 22, 2016, you will provide us with any current sourcing policies, goals, product offerings, or other initiatives seeking to promote antibiotic stewardship. We would also very much welcome a direct discussion with you or your staff to understand your efforts and further explain our concerns regarding this issue. We hope to highlight your positive commitments and to work together to increase the availability of meat and poultry produced without unnecessary antibiotics. Please contact [CONTACT NAME] at [EMAIL AND PHONE] by [WHEN] to determine a time when our team could meet with you to discuss the above. We appreciate your attention to our concerns.

Respectfully,

Jonathan Kaplan Director, Food and Agriculture Program

Page 12 CRYING FOWL: MAJOR GROCERS STUMBLE IN PROMOTING ANTIBIOTIC STEWARDSHIP IN RETAIL CHICKEN NRDC DRAFT APPENDIX 2: DATA TABLES

TABLE A2: SURVEY DATA ON BRAND SOURCING FOR ALL RETAILER CHICKEN BRANDS (MAXIMUM POINTS FOR “NO ROUTINE USE” OF ANTIBIOTICS IS 20; MAXIMUM POINTS FOR CERTIFICATION IS 10)

Retailer City Brand/Producer No Routine Use Certification Chicago, IL Signature Farms/Pilgrim’s Pride N N Perdue Perfect/Perdue Y Y Perdue/Perdue Y N Houston, TX Signature Farms/Sanderson Farms N N Sanderson Farms/Sanderson Farms N N Open Nature/Foster Farms Y N O Organics/Foster Farms Y Y Los Angeles, CA Open Nature/Foster Farms Y N Foster Farms Simply Raised/Foster Farms Y N Signature Farms/Foster Farms Y N Foster Farms/Foster Farms Y N Foster Farms Organic/Foster Farms Y Y Empire Kosher/Empire Kosher Y N O Organics/Foster Farms Y Y Philadelphia, PA Empire Kosher/Empire Kosher Y N Perdue/Perdue Y N Lancaster Brand/Mountaire Farms N N Empire Kosher Organic/Empire Kosher Y Y Harvestland/Perdue Y Y Final score 15/19 (79% of 20 = 15.8) 6/19 (32% of 10 = 3.2)

Retailer City Brand/Producer No Routine Use Certification Charlotte, NC Perdue/Perdue Y N Publix/Tip Top Poultry N N Publix/Pilgrim’s Pride N N Springer Mountain/Fieldale Farms Y N Fresh Hen/Tip Top N N Publix Greenwise/Pilgrim’s Pride Y N Fieldale Farms/Fieldale Farms Y N Murray’s Organic/Shenandoah Processing Y Y Perdue Perfect/Perdue Y Y

Page 13 CRYING FOWL: MAJOR GROCERS STUMBLE IN PROMOTING ANTIBIOTIC STEWARDSHIP IN RETAIL CHICKEN NRDC DRAFT Jacksonville, FL Perdue/Perdue Y N Publix/Pilgrim’s Pride N N Springer Mountain/Fieldale Farms Y N Murrays/MB Consultants Y N Publix Greenwise/Pilgrim’s Pride Y N Young and Tender/Fieldale Farms Y N Perdue Perfect/Perdue Y Y Publix/Tip Top Poultry N N Final score 12/17 (71% of 20 = 14.2) 3/17 (18% of 10 = 1.8)

Retailer City Brand/Producer No Routine Use Certification Charlotte, NC unbranded/Tyson Y N Tyson/Tyson Y N Gold Leaf/Tyson Y N Harvestland Organic/Perdue Y Y Harvestland/Perdue Y Y Claxton Select/Claxton N N Chicago, IL Harvestland/Perdue Y Y unbranded/Tyson Y N Tyson/Tyson Y N Gold Leaf/Tyson Y N Houston, TX Tyson/Tyson Y N Harvestland/Perdue Y Y Gold Leaf/Tyson Y N unbranded/Tyson Y N Harvestland Organic/Perdue Y Y Crescent Foods Y N Jacksonville, FL unbranded/Tyson Y N Tyson/Tyson Y N Perdue/Perdue Y N Gold Leaf/Tyson Y N Claxton Select/Claxton Poultry Farms N N Harvestland/Perdue Y Y

Page 14 CRYING FOWL: MAJOR GROCERS STUMBLE IN PROMOTING ANTIBIOTIC STEWARDSHIP IN RETAIL CHICKEN NRDC DRAFT Los Angeles, CA Harvestland/Perdue Y Y Harvestland Organic/Perdue Y Y Tyson/Tyson Y N unbranded/Tyson Y N Gold Leaf/Tyson Y N Philadelphia, PA Perdue/Perdue Y N unbranded/Amick Farms N N Harvestland/Perdue Y Y Crescent Foods/Crescent Foods Y N Final Score 28/31 (90% of 20 = 18) 9/31 (29% of 10 = 2.9)

Retailer City Producer/Brand No Routine Use Certification Charlotte, NC Kirkland/Pilgrim’s Pride N N Coleman Organic/Perdue Y Y Chicago, IL Perdue/Perdue Y N Kirkland/Pilgrim’s Pride N N Coleman Organic/Perdue Y Y Houston, TX Kirkland/Pilgrim’s Pride N N Coleman Organic/Perdue Y Y Jacksonville, FL Coleman Organic/Perdue Y Y Kirkland/Pilgrim’s Pride N N Los Angeles, CA Foster Farms/Foster Farms Y N Foster Farms Organic/Foster Farms Y Y Philadelphia, PA Kirkland/Pilgrim’s Pride N N Coleman Organic/Perdue Y Y Final Score 8/13 (62% of 20 = 12.4) 6/13 (46% of 10 = 4.6)

Retailer City Producer/Brand No Routine Use Certification Charlotte, NC Perdue Y N Harris Teeter/Sanderson Farms N N Smart Chicken/Tecumsah Farms Y N Organic Smart Chicken/Tecumsah Farms Y Y Harvestland/Perdue Y Y Perdue Perfect/Perdue Y Y Chicago, IL Tyson/Tyson Y N Heritage Farm/Pilgrim’s Pride N N

Page 15 CRYING FOWL: MAJOR GROCERS STUMBLE IN PROMOTING ANTIBIOTIC STEWARDSHIP IN RETAIL CHICKEN NRDC DRAFT Houston, TX Simple Truth Organic/Perdue Y Y Heritage Farms/Pilgrim’s Pride N N Simple Truth/Tyson Y N Pilgrim’s Pride/Pilgrim’s Pride N N No label/Tyson Y N Los Angeles, CA Sanderson Farms/Sanderson Farms N N Simple Truth Organic/Perdue Y Y Foster Farms/Foster Farms Y N Foster Farms Simply Raised/Foster Farms Y N Randall Farms/Randall Foods N N Country Post/Pilgrim’s Pride N N Smart Chicken/Tecumseh Poultry Y N Organic Smart Chicken/Tecumseh Poultry Y Y Simple Truth/Perdue Y N Ralph’s Brand/Randall Foods N N Ralph’s Brand/Foster Farms Y N Final Score 16/24 (67% of 20 = 13.4) 6/24 (25% of 10 = 2.5)

TABLE A3: SURVEY DATA ON CONSUMER EDUCATION Cities where consumer Number of cities where Number of cities with Retailer education images present images present retailer presence Points awarded

Chicago 2 6 0 Los Angeles

Los Angeles Houston 3 4 2.5 Charlotte

Charlotte 2 2 5 Jacksonville

Los Angeles Houston 3 4 2.5 Philadelphia

None 0 6 0

Page 16 CRYING FOWL: MAJOR GROCERS STUMBLE IN PROMOTING ANTIBIOTIC STEWARDSHIP IN RETAIL CHICKEN NRDC DRAFT TABLE A4: COMMITMENTS OF CHICKEN PRODUCERS THAT HAVE PHASED OUT ROUTINE USE OF ANTIBIOTICS Chicken Producer Commitment Foster Farms According to its website: “Foster Farms is working toward a goal of eliminating the use of all antibiotics that are used in human medicine, except in those instances where the clinical health of a flock is at risk . . . The practices below, prescribed by Foster Farms veterinary staff, protect and preserve the effectiveness of antibiotics, while ensuring the welfare of our chicken flocks: 1. Antibiotics will not be used in-ovo, subtherapeutically, or for growth promotion or feed conversion purposes in broiler production. 2. Antibiotics may be used to treat chickens that have a documented microbial disease or for disease control only as dictated by a licensed Veterinarian. 3. Critically important antibiotics in human medicine will not be used to treat, prevent or control disease.”38 Perdue According to its website: “Perdue Farms becomes first major chicken company to eliminate routine use of all antibiotics . . . Perdue veterinarians prescribe an antibiotic treatment for about 5% of the company’s flocks on average, and the treatment is limited to only what is appropriate to the condition affecting a flock. Those chickens are removed from the no-antibiotics-ever program and sold through other channels.”39 Tyson According to its website: “We’ve set a goal to eliminate the use of human antibiotics from our broiler chicken production by September 2017 . . . We have a responsibility to treat sick animals and animal well-being will never be compromised. We’re working with food industry, government, veterinary, public health and academic communities to accelerate research into disease prevention and antibiotic alternatives.” 40

APPENDIX 3: CONSUMER EDUCATION EXAMPLES

FIGURE A2: PROMOTIONAL MATERIALS ON “ORGANIC” OR “RAISED WITHOUT ANTIBIOTICS” CHICKEN ON GROCERY STORE SHELVES

Page 17 CRYING FOWL: MAJOR GROCERS STUMBLE IN PROMOTING ANTIBIOTIC STEWARDSHIP IN RETAIL CHICKEN NRDC DRAFT Page 18 CRYING FOWL: MAJOR GROCERS STUMBLE IN PROMOTING ANTIBIOTIC STEWARDSHIP IN RETAIL CHICKEN NRDC DRAFT FIGURE A3: EXAMPLES OF IN-STORE SIGNAGE ABOVE OR NEAR GROCERY STORE SHELVES DIRECTING CONSUMERS TOWARD CHICKEN OPTIONS

Page 19 CRYING FOWL: MAJOR GROCERS STUMBLE IN PROMOTING ANTIBIOTIC STEWARDSHIP IN RETAIL CHICKEN NRDC DRAFT APPENDIX 4: COMPANY PROFILES41 Costco Owned by: Costco Wholesale Corporation (NASDAQ: COST) Walmart Corporate headquarters: 999 Lake Dr., Issaquah, WA 98027 Owned by: Walton Family (NYSE:WMT)42 CEO: W. Craig Jelinek Corporate headquarters: 702 S. W. 8th St., Bentonville, AR Number of U.S. locations: 476 72712 2015 Sales in U.S: $83 million CEO: Doug McMillon Published policy or companywide statements on antibiotic Number of U.S. locations: 5,182 use: No published policy on company website. 2015 Sales in U.S: $353 million While statements to the media were interpreted as an Published policy or companywide statements on antibiotic antibiotic stewardship commitment, no official antibiotic 44 use: http://corporate.walmart.com/_news_/news- policy has been published on Costco’s website. A Costco archive/2015/05/22/walmart-us-announces-new-animal- representative was reported to have said, “We are working welfare-and-antibiotics-positions towards, and working with our suppliers and the regulatory agencies . . . to see how we can get rid of shared-use Walmart has a published policy and is asking its suppliers antibiotics in animals.”45 No timeline was reported. to limit use of antibiotics to animals that are sick or at risk according to FDA’s Voluntary Guidance for Industry #209, and to publicly report antibiotic use on an annual basis. Albertsons/Safeway Owned by: Cerberus Capital Management, Kimco Realty FDA’s Guidance #209 does not set limits regarding routine Corporation, Klaff Realty, Lubert-Adler Partners, and use of antibiotics for disease prevention; therefore, this Schottenstein Stores Corporation (NYSE:ABS)46 policy would not prevent the routine use of antibiotics. Corporate headquarters: 250 E. Parkcenter Blvd., Boise, ID Kroger 83706 Owned by: The Kroger Co. (NYSE:KR)43 CEO: Robert Miller Corporate headquarters: 1014 Vine St., Cincinnati, OH Number of U.S. locations: 2,311 45202 2015 Sales in U.S: $58 million CEO: W. Rodney McMullen Published policy or companywide statements on antibiotic Number of U.S. locations: 3,747 use: None 2015 Sales in U.S: $103 million Published policy or companywide statements on antibiotic Publix Super Markets Owned by: Privately held by present and past employees47 use: http://sustainability.kroger.com/supply-chain-animal- welfare.html Corporate headquarters: 3300 Publix Corporate Pkwy., Lakeland, FL 33811 Kroger has no published policy on antibiotic use in its supply chains. In its sustainability report, Kroger has stated CEO: William E. Crenshaw that it is committed to evaluate the subtherapeutic use of Number of U.S. locations: 1,314 antibiotics. 2015 Sales in U.S: $32 million Published policy or companywide statements on antibiotic use: http://corporate.publix.com/about-publix/publix-faq/ position-statements Publix has met with its chicken suppliers and discussed the importance of antibiotic stewardship. While the company states that a majority of the chickens in its supply chain do not receive any human antibiotics, the company has made no commitment to phase out routine use of antibiotics. The company continues to source from producers that have remained silent regarding their antibiotic use or have acknowledged their use of antibiotics for disease prevention.48,49

Page 20 CRYING FOWL: MAJOR GROCERS STUMBLE IN PROMOTING ANTIBIOTIC STEWARDSHIP IN RETAIL CHICKEN NRDC DRAFT ENDNOTES 18 The chicken industry is highly vertically integrated. According to the National Chicken Council, “more than 90 percent of all chickens raised for human 1 The Pew Charitable Trusts, “Record-High Antibiotic Sales for Meat and consumption in the United States are produced by independent farmers working Poultry Production,” February 6, 2013, www.pewtrusts.org/en/about/news-room/ under contract with integrated chicken production and processing companies. news/2013/02/06/recordhigh-antibiotic-sales-for-meat-and-poultry-production Most of the other 10 percent are company-owned farms, and less than one (accessed November 14, 2016). percent are raised by individual growers.” National Chicken Council, “Vertical 2 U.S. Food and Drug Administration (hereinafter FDA), Approved Animal Integration, 2012, http://www.nationalchickencouncil.org/industry-issues/ Drug Products (Green Book), February 1, 2016, www.fda.gov/AnimalVeterinary/ vertical-integration/. Only a very small fraction of chicken packages could not Products/ApprovedAnimalDrugProducts/UCM2006464 (accessed November 14, be associated with a poultry producer due to missing brand and processing plant 2016). A subset of the antibiotics administered in food and water is for disease information. Those unidentified products were excluded from the analysis. prevention. FDA, “2014 Summary Report on Antimicrobials Sold or Distributed 19 For score breakdown and grade assignments among different regions and for Use in Food-Producing Animals,” December 10, 2015, http://www.fda.gov/ regional retailers, see Appendix 2, Table A2. animalveterinary/newsevents/cvmupdates/ucm476256.htm (accessed November 14, 2016). 20 Layne, N., “Exclusive: Costco Working to End Use of Human Antibiotics in Chicken,” Reuters, March 5, 2015, http://www.reuters.com/article/us- 3 Da Costa, P. et al., “Effects of Antimicrobial Treatment on Selection of costco-antibiotics-idUSKBN0M201520150306; Horovitz, B., “Costco Working Resistant Escherichia coli in Broiler Fecal Flora,” Microbial Drug Resistance 14, to Restrict Antibiotics,” USA Today, March 6, 2015, http://www.usatoday. no. 4(Dec. 2008):299-306; Berrang, M. et al., “Subtherapeutic Tylosin Phosphate com/story/money/2015/03/06/costco-antibiotics-mcdonalds-food-retail- in Broiler Feed Affects Campylobacter on Carcasses During Processing” Poultry restaurants/24499417/. Science 86, no. 6 (June 2007):1229-33. 21 NRDC, “Chain Reaction.” 4 Centers for Disease Control and Prevention (hereinafter CDC), “Antibiotic Resistance from the Farm to the Table,” November 16, 2015, http://www.cdc.gov/ 22 Here we define conventional chicken as chicken that was produced under foodsafety/challenges/from-farm-to-table.html; Cordova, C., “Antibiotic Resis- the minimum antibiotic use requirements, which allows for antibiotics to be tance: From the Farm to You,” Natural Resources Defense Council (hereinafter administered for growth promotion, disease prevention, disease control, and NRDC), Fact Sheet, March 2015, https://www.nrdc.org/sites/default/files/antibi- treatment. Conventional chicken as defined excludes chicken produced under otic-resistance-farms-FS.pdf. organic production requirements, chicken that is “raised without antibiotics” or with “no antibiotics ever,” and chicken that is raised without the routine use of 5 CDC, Antibiotic Resistance Threats in the United States, 2013, April 2013, antibiotics. Northeast Organic Farming Association of Vermont, “Guidelines for p. 14, http://www.cdc.gov/drugresistance/threat-report-2013/. Organic Certification of Poultry,” https://www.ams.usda.gov/sites/default/files/ 6 American Public Health Association, “‘State of Public Health 2016’ with CDC media/Poultry%20-%20Guidelines.pdf, accessed January 11, 2016. Director Tom Friedman,” Public Health Newswire, January 6, 2016, http://www. 23 Walmart, “Walmart U.S. Announces New Animal Welfare and Antibiotic publichealthnewswire.org/?p=14449. Positions,” May 22, 2015, http://corporate.walmart.com/_news_/news-ar- 7 CDC, “About Antimicrobial Resistance,” September 8, 2015, https://www. chive/2015/05/22/walmart-us-announces-new-animal-welfare-and-antibiotics- cdc.gov/drugresistance/about.html. positions. 8 Routine use of antibiotics refers to the use of medically important antibiotics 24 Perdue Farms, “Antibiotics Position Statement,” 2016, http://www.perdue- for growth promotion or disease prevention rather than to treat animals that are farms.com/News_Room/Statements_and_Comments/details.asp?id=545. sick. 25 Tyson Foods, Inc., “Antibiotic Use,” 2016, http://www.tysonfoods.com/Me- 9 Statista, “Consumers’ Weekly Grocery Shopping Trips in the United States dia/Position-Statements/Antibiotic-Use.aspx. from 2006 to 2016,” 2016, http://www.statista.com/statistics/251728/weekly- 26 Walmart, “Walmart U.S. Announces New Animal Welfare and Antibiotic number-of-us-grocery-shopping-trips-per-household/. Positions.” 10 United States Department of Agriculture (hereinafter USDA), Food Safety 27 Tyson Foods, Inc., “2015 Report on Animal Well-Being,” 2016, http:// and Inspection Service, “Chicken from Farm to Table—Food Safety Information,” www.tysonsustainability.com/animal-well-being; Perdue Farms, “Perdue March 24, 2015, https://www.fsis.usda.gov/wps/portal/fsis/topics/food-safety- Expands No Antibiotics Ever™ Poultry into Mainstream Grocery, Food Ser- education/get-answers/food-safety-fact-sheets/poultry-preparation/chicken- vice,” 2016, http://www.perduefarms.com/News_Room/Press_Releases/ from-farm-to-table/ct_index. details.asp?id=1372&title=Perdue%20Expands%20NO%20ANTIBIOTICS%20 11 USDA, Economic Research Service, “Hogs & Pork Background,” October 6, EVER%99%20Poultry%20into%20Mainstream%20Grocery,%20Foodservice. 2016, http://www.ers.usda.gov/topics/animal-products/hogs-pork/background. 28 See Appendix 2, Table A2. aspx. 29 Meatingplace, “Clean Label Meats Post Rapid Growth: Nielsen,” October 28, 12 Ibid. 2016, http://www.meatingplace.com/Industry/News/Details/69629. 13 NRDC, “Chain Reaction: How Top Restaurants Rate on Reducing Antibiotics 30 Halabi, Sam F., Food and Drug Regulation in an Era of Globalized Markets in Their Meat Supply,” September 20, 2016, https://www.nrdc.org/resources/ (Cambridge, MA: Academic Press, August 31, 2015). chain-reaction-how-top-restaurants-rate-reducing-antibiotics-their-meat-supply. 31 Gallo, A.C., “Our Meat: No Antibiotics Ever,” Whole Foods blog post, June 14 Our survey was conducted to obtain a picture of chicken brand choices 25, 2012, http://www.wholefoodsmarket.com/blog/whole-story/our-meat-no- from the five major retailers in six major metropolitan areas from each of the antibiotics-ever-0. four major regions delineated by the U.S. Census during a single season. It was impractical to study the sourcing practices of the five major retailer chains (or 32 Whole Foods Market, Meat Department, “Animal Welfare,” August 2012, their regional chains) at all of their locations across the country and throughout http://www.wholefoodsmarket.com/sites/default/files/media/Global/PDFs/5- the year. In each metropolitan area, at most three locations were visited per major step-meat-brochure.pdf. retailer; therefore, the survey may not represent the entire selection of chicken at 33 School Food Focus, “Certified Responsible Antibiotic Use,” 2016, http://www. every retailer within the selected city. schoolfoodfocus.org/the-crau-standard/. 15 National Retail Federation, “Top Retailers 2016,”, 2016, https://nrf.com/ 34 NRDC, “Chain Reaction.” resources/annual-retailer-lists/top-100-retailers/stores-top-retailers-2016; Supermarket News, “2015 Top 75 U.S. & Canadian Food Retailers & Wholesalers,” 35 United States Census Bureau, “City and Town Totals: Vintage 2014—Annual 2016, http://supermarketnews.com/2015-top-75-us-canadian-food-retailers- Estimates of the Resident Population for Incorporated Places of 50,000 or More, wholesalers. Ranked by July 1, 2014 Population: April 1, 2010 to July 1, 2014,” May 21, 2015, http://www.census.gov/popest/data/cities/totals/2014/index.html. 16 United States Census Bureau, “City and Town Totals: Vintage 2014—Annual Estimates of the Resident Population for Incorporated Places of 50,000 or More, 36 The following websites were used to map store locations in each of the cities: Ranked by July 1, 2014 Population: April 1, 2010 to July 1, 2014,” May 21, 2015, http://www.walmart.com/store/finder, https://www.kroger.com/storeLocator, http://www.census.gov/popest/data/cities/totals/2014/index.html. http://store.publix.com/publix/, https://www.costco.com/warehouse-locations, http://albertsons.mywebgrocer.com/Stores, http://albertsons.mywebgrocer.com/ 17 See Appendix 1 for definition of unique brand choice. Stores, http://www.safeway.com/ShopStores/tools/store-locator.page.

Page 21 CRYING FOWL: MAJOR GROCERS STUMBLE IN PROMOTING ANTIBIOTIC STEWARDSHIP IN RETAIL CHICKEN NRDC DRAFT 37 WATT Poultry USA, “WATT PoultryUSA’s 2016 top broiler companies,” 2016. http://www.wattpoultryusa-digital.com/201603/. 38 Foster Farms, “Antibiotic Stewardship,” 2016, https://www.fosterfarms.com/ because-we-care/antibiotic-stewardship/. 39 Perdue Farms, “Perdue Farms Becomes First Major Chicken Company to Eliminate Routine Use of All Antibiotics,” October 7, 2016, http://www.perduefarms.com/News_Room/Press_Releases/details. asp?id=1456&title=Perdue%20Farms%20becomes%20first%20major%20 chicken%20company%20to%20eliminate%20routine%20use%20of%20all%20 antibiotics. 40 Tyson Foods, Inc., “Antibiotic Use.” 41 National Retail Federation, “Top Retailers 2016”; Supermarket News, “2015 Top 75 U.S. & Canadian Food Retailers & Wholesalers.” 42 Walmart, “Our History,” 2016, http://corporate.walmart.com/our-story/our- history. 43 Kroger Corporate, “About Kroger,” 2016, http://www.thekrogerco.com/ about-kroger. 44 Costco, Ref. 20. 45 Costco, Ref. 20. 46 Safeway, Inc., “Albertsons and Safeway Complete Merger Transaction,” January 30, 2015, http://www.albertsons.com/albertsons-and-safeway-complete- merger-transaction/. 47 Publix, “Facts and Figures,” 2016, http://corporate.publix.com/about-publix/ company-overview/facts-figures. 48 Tip Top Poultry, “Our Company,” 2016 http://tiptoppoultry.com/corevalues/. 49 Pilgrim’s, “Frequently Asked Questions – Do your chickens receive any antibiotics?,” http://www.pilgrims.com/contact-us/faq.aspx. (accessed November 3, 2016).

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